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Principal Commissioner of Income Tax-6 vs Nokia Siemens Networks India Pvt. Ltd. | Delhi High Court | Section 37 & Section 41(1) | Provision for Liquidated Damages as Ascertained Liability
Facts of the CaseThe present appeal pertains to Assessment Year 2004–05,
where the Revenue challenged the order of the Income Tax Appellate Tribunal
(ITAT) dated 31.01.2018. The respondent/assessee, Nokia Siemens Net...
Principal Commissioner of Income Tax (Central)-3 vs Bhilwara Energy Ltd. | Section 14A Disallowance Not Applicable Where No Exempt Income Earned | Delhi High Court
Facts of the Case
The
Revenue filed appeals against a common order of the Income Tax Appellate
Tribunal (ITAT) dated 02.08.2022.
The
Tribunal had deleted disallowance made under Section 14A for
...
AVS Infrabuild Private Limited vs Assistant Commissioner of Income Tax & Ors. – Invalid Reassessment Notice under Section 148 due to Jurisdictional Errors | Section 148, 148A(d), 292B Income Tax Act
Facts of
the CaseThe petitioner, AVS Infrabuild Private Limited, challenged
reassessment proceedings initiated by the Income Tax Department for AY 2014–15.
The challenge was directed against:
Notice
under Se...
Principal Commissioner of Income Tax (Central)-3 vs Bhilwara Energy Ltd | Section 14A Disallowance Not Applicable Where No Exempt Income Earned (Delhi High Court)
Facts of the CaseThe Revenue filed multiple appeals challenging a common order
passed by the Income Tax Appellate Tribunal (ITAT) dated 02.08.2022. The
Tribunal had deleted the disallowance made under Section 14A of th...
Pr. Commissioner of Income Tax-7 vs Yakult Danone India Pvt. Ltd. – AMP Expenses & Bright Line Test Not an International Transaction | Delhi High Court (ITA 208/2023)
Facts of the CaseThe present appeal was filed by the Revenue (Pr. Commissioner
of Income Tax-7) before the Delhi High Court challenging the order of the
Income Tax Appellate Tribunal (ITAT) dated 06.10.2020 for Assessm...
Pr. Commissioner of Income Tax–6 vs Nokia Solutions & Networks India Pvt. Ltd. (Delhi High Court) – Provision for Liquidated Damages & Unascertained Liability under Income Tax Act, 1961
Facts of the CaseThe appeal was filed by the Revenue challenging the order
passed by the Income Tax Appellate Tribunal dated 31.01.2018.The dispute pertained to deletion of an addition amounting to ₹3,24,11,982,
whic...
PR. Commissioner of Income Tax–7, Delhi vs M/s Reservation Data Maintenance India Pvt. Ltd. (Delhi High Court) – Exclusion of Comparables in Transfer Pricing (AY 2009–10)
Facts of the CaseThe present appeal pertains to Assessment Year 2009–10,
wherein the assessee, engaged in Information Technology Enabled Services
(ITES)/BPO services and online data processing, filed its return decla...
Pinki Tour and Travels Limited vs Income Tax Department – Delhi High Court sets aside reassessment order for non-consideration of reply under Section 148A(d) of Income Tax Act, 1961 (AY 2016–17)
Facts of the Case
The
petitioner, Pinki Tour and Travels Limited, challenged an order dated
31.03.2023 passed under Section 148A(d) of the Act.
The
case pertains to Assessment Year 2016–17.
A
...
Merilina Foundation vs Assistant Commissioner of Income Tax – Reassessment Validity under Sections 147 & 148 and Remand of Tribunal Order
Facts of the Case
The
case pertains to Assessment Year 2011–12.
The
assessee, Merilina Foundation, challenged the order of the Income
Tax Appellate Tribunal (ITAT) dated 16.11.2022.
The
...
Devasan Investments Pvt. Ltd. vs Income Tax Officer, Ward 7(1), Delhi & Ors. – Delhi High Court (31 July 2023) | Breach of Natural Justice under Section 144B(6)(xi) of Income Tax Act
Facts of the CaseThe petitioner challenged the assessment order dated
24.05.2023 concerning Assessment Year 2013–14.A show-cause notice (SCN) dated 05.05.2023 was issued
requiring the petitioner to respond by 08.05.2...